Corporate Reorganizations Under Sections 51 and 86

Section 86 and 51 Corporate Reorganizations is a focused, practical course designed to help accounting and tax professionals understand and apply two of the most important corporate reorganization provisions in the Income Tax Act. This course provides a clear and structured examination of Section 51, which governs tax-deferred exchanges of convertible property, and Section 86, which applies to reorganizations of a corporation’s capital. Learners will explore how these provisions are used in real-world planning situations, including estate freezes, business succession strategies, shareholder restructurings, and capital realignments. The course explains the eligibility conditions that must be satisfied for each provision, including capital property requirements, the treatment of non-share consideration, and the necessity of a reorganization of capital under Section 86. It also addresses the detailed tax implications of these transactions, including adjusted cost base continuity, paid-up capital limitations, deemed dispositions, and the operation of anti-gifting rules. Step-by-step calculation examples and applied case studies help connect the legislation to practical advisory work. By the end of the course, participants will have a stronger understanding of how to structure share exchanges in a tax-efficient manner, identify common compliance risks, and analyze when Section 51, Section 86, or alternative provisions such as Section 85 may be more appropriate. The emphasis throughout is on practical application, technical accuracy, and professional judgment in planning and implementation. Delivered online and self paced through the Canadian Accountant Training Institute, the course includes comprehensive video instruction, downloadable reference materials, and knowledge-check quizzes to reinforce learning. It is suitable for professionals seeking to deepen their expertise in corporate tax planning and enhance their confidence when advising on corporate reorganizations.